ML18054A521

Forwards Listing of Outstanding Tech Specs Change Requests, Including Summary of Proposed Action

ML18054A521
Person / Time
Site:	Palisades
Issue date:	01/24/1989
From:	Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8902010041
Download: ML18054A521 (7)

Text

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consumers Power POWERiNii NllCHlliAN"S PROliRESS General Offices: 1945 West Parnell Road, Jackson,- Ml 49201 * (517) 788-0550 January 24, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

OUTSTANDING TECHNICAL SPECIFICATIONS CHANGE REQUESTS In Consumers Power Company's, September 23, 1988 response to the NRC SALP 8 repor~ for Palisades, we noted our participation in the industry-NRG effort to develop improved~ Technic_gl Spec'ifications. Our goal is to submit ;restructured Palis~des Technical Specifica~ions following the lead Combustion Engineering plant's (San Onofre) submittal in early 1990.

Our SALP 8 response also noted we would review and prioritize our list of outstanding Technical Specif icat~ons Change Requests (TSCRs) and provide the NRC an opportunity to review the list. We met with the NRC's Palisades Project Manager, TVWambach, on October 20, 1988 to review the list. Following the meeting, we determined that several of the TSCRs pending resubmittal by Consumers Power Company, as well as others pending approval by the NRC, should be reprioritized. We again met with Mr Wambach and the new Palisades Project Manager AWDeAgazio on December 16, 1988 to discuss the prioritization of the TSCRs.

The prioritization discussed with Messrs Wambach and DeAgazio delegates nearly all of the outstanding TSCRs to two groups. The first group are those TSCRs we are requesting to be withdrawn and which will Qe factored into the Palisades' restructured Technical Specifications effort. The second group are those TSCRs for which NRC approval is being requested._ The remaining two TSCRs will be addressed in the short-term, during 1989. This prioritization would relieve Consumers Power Company resources to concentrate on the restructured Technical Specifications effort and also relieve the NRC, in the short term, of their review anq approval tasks associated with the backlogged

_TSCRs that' are being withdrawn. The two exceptions are discussed in the attached table-. For those TSCRs that are being withdrawn, we commit to maintaining the technical requirements active through administrative controls until approval is obtained for the restructured Technical Specifications.

This commitment applies to only those TSCRs which are more restrictive or which~add requirements to the present Technical Specifications.

OC1088-0180-NL02

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'::702010041 890124

P[IR ADOCI< 05000255 p PDC Irn-.' A CM5 ENERGY COMPANY

Nuclear Regulatory Commission Palisades Plant Outstanding TSCRs January 24, 1989

• 2 The TSCRs we intend to pursue with the NRC in the short-term will be those which pose a unique concern, are of immediate need ~r benefit to Palisades, or are consistent with the NRC's short-term Technical Specifications improvements.

We request NRC's support by completing the required TSCRs reviews, that remain on the Docket, within the next 4 to 6 months.

With respect to short-term improvements, we intend to submit changes consistent with Generic Letters 87-09 (Sections 3.0 and 4.0 of the Standard Technical Specifications) and 86-10 and 88-12 (Removal of Fire Protection Requirements) over the next several months.

Attached is a listing of the outstanding Technical Specifications Change Requests which includes a summary of proposed action.

Two change requests (dated May 14, 1980 and November 12, 1981) previously withdrawn via letter dated March 5, 1986, and concurred with by NRC letter.

dated May 28, 1986 are subject to resubmittal, as stated in the NRC letter.

Instead of a resubmittal, will factor any necessary changes from these two withdrawn requests into the restructured Technical Specifications.

~~

mes L Kuemin aff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment OC1088-0180-NL02

1 OUTSTANDING TECHNICAL SPECIFICATIONS CHANGE REQUESTS ' , ,

Submittal/

Rev Date Subject Comments

(

1. 8/21/80 DefiniUon of CPC requests ~ithdrawal. Portions of this TSCR have been Operability superseded by Amendment 85. The definition of operability in (TAC No M43052) Standard Technical Specifications (STS) is used when interpretation of operability is required. The STS definition will be factored into the restructured Technical Specifications (RTS).

2. 11/24/80 Containment Spray CPC requests withdrawal. Palisades Plant will continue to maintain the LCOs for this proposed change with appropriate administrative controls. The change will be factored into the RTS.

3. 12/3/80 Undervoltage Protection CPC requests withdrawal. The LCOs proposed in this change have SEP Topic VIII-1.A been determined to be inappropriate and require revision.

Resubmittal with appropriate changes will be factored into the RTS. (Reference NRC SER of 12/22/81)

4. 7/6/81 Heat Balance CPC requests withdrawal. Admendment 11~ included a

• Surveillance requirement to conduct the surveillance when above 15% power and supersedes the need for this change request.

5. 3/3/82 Airlock Leak Test NRC approval requested. We believe our March 21, 1988 Rev 3/21/88 (TAC No M64339) letter corrected.the TSCR and it is now acceptable to the NRC reviewer.

6. 6/25/82 I&C RPS & ESFAS CPC reguests withdrawal. Appropriate changes to requirements for the present Technical Specifications (TS) for RPS and ESFAS will be incorporated into the RTS.

. 7. 8/30/82 PCS Gas Vent CPC requests withdrawal. The PCS gas vent requirements 4/21/88 NUREG-0737 Item II.B.l proposed in the TSCR will be maintained under appropriate (TAC No M54405) administrative controls and will be established so that .

changes are reviewed in accordance with 10CFR50.59.

Removal from the TS is consistent with the NRC's conclusions as to which STS requirements are to be retained in the restructured STS (TEMurley, NRC, to JKGasper, CEOG, May 9, 1988.).

TSCR-NL04

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2 OUTSTANDING TECHNICAL SPECIFICATIONS CHANGE REQUESTS , j Submittal/

Rev Date Subject Comments

8. 11/5/82 NUREG-0737 Items II.F.1.1, CPC requests withdrawal. The Stack Effluent Noble Gas and

.2, .3 & .6 Noble Gas Particulate Monitors and the Main Steam Safety and Dump Valve Effluent Sampling of Discharge Monitor are currently in the RETS section of the TS.

Plant Effluent Contain~ The containment hi-range radiation monitor and containment ment Hi-Range Radi.ation hydrogen monitor requirements will be maintained under and Conta.inment Hydrogen administrative controls for the interim. However, due to Monitors excessive required maintenance on the hydrogen monitoring (TAC No. M54555) system containment isolation valve position indicators, the daily check, which was accomplished by opening the isolation valves and comparing the readings of both the hydrogen monitors, will be eliminated. This supersedes our Material Condition Task Force item CIS-04 in CPC letter of December 1, 1986. All required changes will be factored into RTS.

9. 4/ 10/84 Addition of 480V CPC requests withdrawal. Pending approval of the Palisades rev 3/25/86 distribution Buses & RTS, the portions of this TSCR that supplement the present redistribution of MCC TS will remain under administrative controls.

(TAC No. M54795)

10. . 11/19/84 Control Room Hab~tability CPC requests withdrawal.* Changes may be necessary following rev 11/21- 0737 Item III.D.3.4 current analysis for control room habitability. The changes 22/85, (TAC No M 56867) will be incorporated into administrative controls and rev 2/28/86 factored into the RTS submittal.

11. 2/5/85 Inspection & Testing CPC requests this TSCR remain on hold, pending our request to 11/21/85 of Fire Protection remove and relocate the present Fire Protection TS requirements Rev 11/22/85 Devices to alternate procedures.

Rev 3/9/87 (TAC No. M57255)

TSCR-NL04

• • 't-3 OUTSTANDING TECHNICAL SPECIFICATIONS CHANGE REQUESTS ' ' -~*

Submittal/

Rev Date Subject Comments

12. 4/30/85 Shutdown Cooling System CPC intends to submit a revision in the near future.

(TAC No M42130)

13. 5/13/85 Station Battery Service NRC approval requested. Questions have been resolved with Rev 2/2/88 & Discharge NRC and we believe the proposal requires only minor NRC (TAC No. M67411) review.

14. 5/23/85 Leakage Detection CPC requests withdrawal and commits to reevaluate SEP Topic System III-5.A with respect to the Containment Atmospheric Gaseous Radiation (TAC NO. M53545) Monitor then submit an appropriate revision during the RTS. In the interim, the remaining leakage detectors described in the TSCR will be incorporated in appr~priate administrative controls.

15. 07/30/85 HPSI Flow Instruments NRC approval requested. HPSI flow instruments are not in present STS.

(TAC No M59310) The HPSI flow instruments per RG 1.97 are Category 2, Type D instruments used to monitor flow. Category 2, Type D instruments are not required TS equipment per NRC letter, TEMurley, to J K Gasper, CEOG, May 9, 1988. Murley's letter incorporates only Category 1 Type A variables', which meet criterion 3 of the NRC's interim policy statement on TS improvements, into the restructured STS. The.refore, t1Ji...

HPSI instruments may be removed from the TS. ~

16. 11/21/85 Core Exit Thermocouples NRC approval requested." The September 1988 resubmittal should Rev 10/25/87 resolve NRC comments.

Rev 9/2/88

17. 11/21/85 Alternate Shutdown & NRC approval requested of the Alternate Shutdown portion of this Emergency Lighting TSCR. The Emergency Lighting Systems portion of this TSCR is to Systems remain on hold pending our submittal on Fire Protection TS discussed above (No 11).

TSCR-NL04

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4 OUTSTANDING TECHNICAL SPECIFICATIONS CHANGE REQUESTS Submittal/

Rev Date Subject Comments

18. 10/20/86' Containment Air Cooler NRC approval requested. *This represents only a minor TS Rev 4/30/87 Design Feature revision to Section 5.2.3.

19. 2/25/87 RAS Actuation Logic NRC approval requested. This change corrects the (TAC No M64784) actuation system logic requirements.

20. 3/10/87 RETS Corrections NRC approval requested. It appears that consideration (TAC No M64992) for a RETS rule change will not be forthcoming in the near future.

21. 5/3/88 Refueling Boron CPC requests withdrawal. The proposed requirements will be Concentration used for interpretation and subsequently factored into (TAC No 69583) the RTS.

22. 8/4/88 Core Cooling NRC approval requested. The TSCR incorporates changes Instrumentation consistent with Generic I.etter 83-37. Our implementation (TAC No M69224) letter of January 9, 1988 documented completion of CPC's required actions.

23. 9/15/88 Containment Isolation NRC approval requested. This change will implement requirements System like the present STS and is of mutual interest to CPC and NRC.

24. 9/21/88 Remove Organization NRC approval requested. This change is in accordance with Charts Generic Letter 88-06 and a short-term TS improvement.

(TAC No 69559)

25. 9/23/88 PRC, NSSD, & PSL NRC approval requested. These changes are benef1cial to CPC Rev 1/16/89 (TAC No 69584) as they will strengthen both onsite and offsite review efforts.

TSCR-NL04

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OUTSTANDING TECHNICAL SPECIFICATIONS CHANGE REQUESTS . .*

~

Submittal/

Rev Date Subject Couunents

26. 10/6/88 Linear.Heat Rate CPC requests withdrawal. This recent change rearranges the (TAC No 69587) Specifications to provide clarification. In the interim, it will be used for interpretation purposes and factored into the RTS.

TSCR-NL04